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UK’s FSA issues Mortgage Market Review: Proposed Package of Reforms
January 15, 2012
At the end of 2011 the Financial Services Authority of the
United Kingdom, published its proposals for reforms of the mortgage sector. It
is soliciting comments which should be in by March 30, 2012. It is a hefty
document with close to 600 pages. At the core of the proposed reforms are three
principles of good mortgage underwriting:
- Mortgages and loans should only be advanced
where there is a reasonable expectation that the customer can repay without relying
on uncertain future house price rises. Lenders should assess affordability.
- This affordability assessment should allow for
the possibility that interest rates might rise in future: borrowers should not
enter contracts which are only affordable on the assumption that low initial
interest rates will last forever.
- Interest-only mortgages should be assessed on a
repayment basis unless there is a believable strategy for repaying out of
capital resources that do not rely on the assumption that house prices will
rise.
At the core of the responsible lending proposals is the
principle of affordability, rather than relying to a significant extent on the
underlying collateral and the assumption that property prices appreciate. This
principle has three key elements:
- The
affordability assessment: a lender must verify income and be able to demonstrate
that the mortgage is affordable taking into account the borrower’s net income
and, as a minimum, both the borrower’s committed expenditure (which includes
the mortgage payments) and basic household expenditure.
-
The
interest rate stress test: the lender must also take account of the impact
on mortgage payments of market expectations of future interest rate increases.
-
The
interest-only proposals: the lender must also assess affordability on a
capital and interest basis, unless there is a clearly understood and believable
alternative source of capital repayment.
No LTV caps are proposed.
While recognizing the other initiatives by the European Union and the Financial Stability Board/BIS to establish a regulatory framework for the mortgage sector (see earlier news posts), it is recognized that these proposals take a higher level approach than the FSA, but are, in principle, closely aligned.
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